Starbucks And Transfer Pricing: Mystery of the intimacy

The really important things in any biography are what someone thinks and feels and not what he has done.
         ~ Glenn Gould

ATO receives record-breaking 15,000 tip-offs to Tax Integrity Centre amid black economy blitz

William Byrnes (Texas A&M), Boiling Starbucks’ Roasting Down to the Essence of its Residual:

The crux of the legal issue is the EU Commission’s contention, required as the third condition for a finding of State aid, that the Netherlands-Starbucks APA conferred a selective advantage on Starbucks' Netherlands manufacturing subsidiary (SMBV, aka the “roasting operation”) that resulted in a lowering of SMBV’s tax liability in the Netherlands as compared with what SMBV would have paid under the Netherlands’ general corporate income tax system dealing with third parties. And the crux of the dispute that determines the legal issue outcome is whose choice of transfer pricing method (the Commission or The Netherlands/Starbucks) is the most reliable. However the most interesting aspect of the controversy is how to allocate the residual between SMBV and Starbucks intermediary IP management limited partnership? In a broader framework, not part of the analysis contemplated by the applicable 1995 OECD Transfer Pricing Guidelines, is how to allocate the residual among Starbucks’ global value chain. This paper, currently a working draft, will eventually address the last two issues.

The New Yorker, The French Economist Who Helped Invent Elizabeth Warren’s Wealth Tax:

Gabriel Zucman and his colleagues are advocating a progressive wealth tax as a solution to global inequality, one that rethinks both evasion and the goals of taxation. ...

To trace the progress of the wealth tax from a fringe academic idea to the center of the Democratic Presidential primary, it is helpful to begin a bit off-center. On September 15, 2008, the day that Lehman Brothers filed for bankruptcy, a twenty-one-year-old student of Thomas Piketty, Gabriel Zucman, started work as a trainee economic analyst in the offices of a Paris brokerage house called Exane. Zucman felt obviously underequipped for the task before him: to write memos to the brokerage house’s clients and traders helping to explain why the very durable and minutely engineered global financial system appeared to be on the verge of collapse. Poring over some of the data he was given, which concerned the international flows of investments, Zucman noticed some strange patterns. The amount of money that had been moving through a handful of very small economies (Luxembourg, the Cayman Islands, the tiny Channel Islands of Jersey and Guernsey) was staggering. “Hundreds of billions of dollars,” Zucman recalled recently, making the “B” in “billions” especially emphatic. Eventually, he would calculate that half of all foreign direct investment—half of the risk-seeking bets, placed from overseas in India, China, Brazil, and Silicon Valley, and of the safety-seeking investments, placed in the United States and Europe and stock indexes—was moving through offshore hubs like these.

JACK WATERFORD. Thin pickings from big bikkies

Britain’s ‘war’ on organised crime is failing, and it’s probably the same here

Some fresh and depressing evidence for those who, like me, fear that federal law enforcement is a good deal less effective and efficient than it could be, because of the way its resources are configured, led, and under the close and very unaccountable supervision of ministers and bureaucrats. Continue reading →b

FIONA STURGES. Snobs,Brexit and Lady Hale (The Guardian, 27 September 2019)

For all the talk of an industry in crisis, you have to hand it to the British media for their ability to get to the nub of a story. It was, one imagines, with a gasp of triumph that the Daily Mail was able to deliver a stinging blow to the president of the supreme court, Lady Hale, she of the spider brooch and the damning verdict on our prime minister’s prorogation wheeze. Via a stunned headline, the paper was this week able to reveal thatHale, who graduated top of her class at Cambridge in law, who was the first woman to be appointed to the Law Commission, and the second to be appointed to the court of appeal, was in fact an “ex-barmaid”. Truly, we must applaud this mighty organ’s dogged commitment to truth and scrutiny. Continue reading →

 People happily talk about the mystery of poetry and of literature. They talk about it ad nauseam. However, nothing is explained, I have to confess, by alluding here to magic or religious ecstasy, wishing stones or observant animals. To talk about the ineffable is to say precisely nothing at all. To talk about secrets is to confess nothing. Poets may indeed be devout, but to what are they devoted? Writers may know a great deal, but what kind of knowledge is it? 


You can’t change the world

But you can change the facts
When you change the facts
You change points of view
When you change points of view

You may change a vote
And when you change a vote
You may change the world

With 'The Border,' Don Winslow closes modern literature's most ...

Nick Caistor reviews Enrique Vila-Matas' Dublinesca, his new novel in Spanish. 

Vila-Matas insists that there is a "moral contract" between writer and reader, and that the reader should be active, showing a "capacity for intelligent emotion, a wish to understand the other person, and to get closer to a language that is different from that of our daily tyrannies". He goes further, declaring that: "the same skills needed to write are also needed to read. Writers can fail readers, but the reverse is also true, and readers fail writers when all they look for in them is a confirmation that the world is exactly how they see it". In spite of all the playfulness therefore, the game of literature is the most serious and urgent there is.

The review is behind the TLS' subscriber paywall yet, for such diligence, sensitivity and happy seriousness, it is worth the outlay. Elsewhere in the paper, Gabriel Josipovici provides the background to his unhappy attempt to speak about such issues to a few of our daily tyrannies and concludes:

[T]hough critics and reviewers in the English language today pay lip service to T. S. Eliot and Virginia Woolf, and even Beckett and Borges, they seem not to have grasped what it was these writers were up to, the radical nature of their critique of the arts in our time. That is what [What Ever Happened to Modernism?] is about, though it seems that in England today journalists are only interested in raking mud.

Try again. Fail again. Fail better', surely the most misread sequence in all of Beckett. He would have been horrified to see it appropriated as a catch-all stoic maxim (e.g. 'OK, you're destined to fail, but never mind, keep trying, keep failing in such a way that your failures come closer to success'). Beckett would have poured scorn on this sort of chocolate-box philosophy. The intended meaning is, directly and literally, 'fail more fully, more catastrophically. Absolutize your failure.'

Two paths for absolutising failure

In a metafictional sleight of hand, the diarist wonders if this restraint is enough, a move that raises the issue of intention and mastery. If the fiction is under the author's control, the expression of limits and pained distance suggest that literary fiction is a charade and is as useless as the grandfather's notebook for providing access to experience. The diary format is then a sop to our enduring gullibility. History, he decides, might be "nothing but the accumulation of massacres that lie behind every speech, every gesture, every memory", which would mean every aspect of this unhappy situation is itself the legacy and revelation of disastrous history: 

... if Auschwitz is the tragedy that contains in its essence all those other tragedies, it's also in a way proof of the non-viability of human experience at all times and in all places – in the face of which there is nothing one can do or think, no possible deviation from the path my grandfather followed during those years.
                                                                                  (Translated by Margaret Jull Costa)

Demons (pre-reform Russian: Бѣсы; post-reform Russian: Бесы, tr. Bésy; sometimes also called The Possessed or The Devils) is a novel by Fyodor Dostoevsky, first published in the journal The Russian Messenger in 1871–72

It is perhaps no coincidence that of Dotoevsky's The Devils Thomas Bernhard wrote: "Never in my whole life have I read a more engrossing and elemental work". These adjectives are the words I would have used to describe his own books when I discovered them, written it seemed to me on the edge of collapse. Aged 19 and expected to die of TB (the initials might be more appropriate than the full name) he read the book in a hospital bed:

It had the effect of a powerful drug, and for a time I was totally absorbed by it. For some time after my return home I refused to read another book, fearing that I might be plunged headlong into the deepest disappointment. For weeks I refused to read anything at all. The monstrous quality of The Devils had made me strong; it had shown me a path that I could follow and told me that I was on the right one, the one that led out. I had felt the impact of a work that was both wild and great, and I emerged from the experience like a hero. Seldom has literature produced such an overwhelming effect on me.  

Twenty years later, living on but still threatened by constant ill-health, he published The Lime Works, a novel beginning with an ellipsis and in the midst of hearsay and speculation:

... when Konrad bought the lime works, about five and a half years ago, the first thing he moved in was a piano he set up in his room on the first floor, according to the gossip at the Laska tavern, not because of any artistic leanings, says Wieser, the manager of the Mussner estate, but for relaxation, to ease the nervous strain caused by decades of unremitting brain work, says Fro, the man in charge of the Trattner estate, agreeing that Konrad's piano playing had nothing to do with art, which Konrad hates, but was just improvisation, as Wieser says, for an hour first thing early in the morning and another late at night, every day, spent at the keyboard, with the metronome ticking away, the window open ..."

NO ONE IS BORN IN A PERFECT WORLD. AND THE QUESTION SHOULD ALWAYS BE: PERFECT, ACCORDING TO WHOM?   Selling Out Paradise.

One is a young, dynamic Treasurer who thrives in the limelight and almost certainly sees himself as a future Liberal Party leader. The other is an even younger, dynamic Treasurer who thrives in the limelight and who many of his colleagues expect will become a Liberal Party leader.

The former is deputy Liberal leader Josh Frydenberg, whose long-range positioning to one day succeed Prime Minister Scott Morrison is obvious to anyone with a passing interest in politics. The latter is his NSW counterpart, Dominic Perrottet, whose long-downtrodden conservative faction prays will be the state's next premier.
The man who would end the stamp duty curse

If you’re so smart, why aren’t you rich? Turns out it’s just chance. MIT Technology Review. We’ve been saying that for some time…

TOWARDS A DEMOCRATIC SOCIALIST FOREIGN POLICY Current Affairs. UserFriendly: “It’s a start, but I wonder if it wouldn’t ramp up R2P sentiment by accident.”

How a major U.S. farm lender left a trail of defaults, lawsuits Reuters 

The End Of College Is Coming Forbes

“The boat appeared to be hanging, as if by magic,… upon the interior surface of a funnel

American Farming Runs on ExploitationNew Republic

Facebook Pledges $1 Billion for California Housing New York Times. We saw this movie in the mortgage settlement. “Grants, loans and land” = funny money. 

Some Good News for North Coast Wiyot Tribe North Coast Journal. Glenn F: 

The Wiyot Tribe’s acquisition of Indian Island: It’s a move without precedent across the nation, according to numerous experts consulted for this story, all of whom said that while there have been instances of the federal government, nonprofits and private entities returning land to tribes, Eureka appears to be the first local municipality to have ever taken such a step.

Courthouse News Service: “Rejecting arguments that Facebook users suffered no “concrete harm” by having their facial data mapped and stored, the Ninth Circuit advanced a $35 billion class action against the social media giant Thursday. Facebook sought to swat down the lawsuit last year after U.S. District Judge James Donato ordered it to alert users about an upcoming trial on claims that it harvested facial data in violation of an Illinois privacy law. The Ninth Circuit granted Facebook’s eleventh-hour request for a stay pending appeal in May 2018. A lawyer representing a class of Facebook users said the ruling sends a strong message that Facebook can be held accountable for failing to protect people’s private information. “This biometric data is very sensitive. It’s as unique as a fingerprint,” said attorney Shawn Williams, of the firm Robbins Geller Rudman & Dowd in San Francisco…”

Inside Trump's first Pentagon briefing Guy Snodgrass, via Politico What I saw there that foretold the coming rift between Mattis and the president—and today’s foreign policy crises.

At last, we hear the beautiful — and sometimes bawdy — Persian poems by women Michael Dirda, via Washington Post Their words leave nothing veiled, as in a four-line outburst by the 15th-century Mehri, “an answer to an old man who proposed himself as her lover”.

Why conservatives loved Mark Zuckerberg’s Georgetown speech Will Oremus, via Medium It justified the status quo in a zeitgeist demanding (soft) revolution.